1. The policy
Guided by the ROCKWOOL Group values, our employees will build appropriate relationships with our business partners and other stakeholders. Good own judgement will always be required as not all situations can be covered by rules and guidelines. We seek an appropriate balance between building, maintaining and expanding strong relationships on the one hand whilst ensuring that our professionalism is maintained and our integrity not impaired / jeopardized on the other hand.
The following general principles for conduct in our relationships with business partners and other stakeholders are to be followed:
a) We trust our employees to make sound judgements.
b) When in doubt, employees will seek guidance and confirm with their manager.
c) Any behaviour to be avoided that might pose a (perceived) threat to the independence of ourselves as well as of the business partner.
d) In case a business partner has a business ethics policy which is more stringent than ours, we will comply with his/her requirements.
e) We consider “reasonable activities” to be those that are not viewed as excessive by a rational and informed third party taking into consideration that we operate a global company.
f) We comply with laws, regulations and standards that apply to us in our professional conduct.
Of particular interest to the area of business ethics, the importance of compliance with the following Group policies is noted:
a) Business responsibility.
b) Risk Management.
c) Corporate Social responsibility.
2. The manual
2.1. Bribery
Bribery consists of methods of unethical character to get ahead of the competition or to receive undue advantages. Bribery is illegal. The ROCKWOOL Group employee does not get involved in any form of bribery.
2.2. Fair competition
Customers will buy our products and systems because they represent the best value in the market – not because we bribe or give undue advantages.
2.3. Procurement
The same principle is valid for procurement. Contracts with suppliers provide the best products and services at the optimum competitive price.
2.4. Family and friends
Business relationships with family and friends should be avoided to the highest extent possible. In case this is not feasible the employees’ manager and OPCO Management are to be informed in writing in advance.
2.5. Avoidance of third parties
We strive to the highest degree to deal directly with links in the supply chain who adds physical and measurable value to our business. We define third parties as agents who are promoting our products/services to the next link in the chain but do not add measurable value. We wish to avoid use of third parties to the minimum, however not losing business opportunities without good reasons. In such situation, employees should seek guidance from their superior. Use of third parties must be approved at OPCO management level and will be specifically monitored and audited from a Group perspective.
3. Facilitation payments
Facilitation payments are standard in many countries and can be defined as payment of an additional fee to public bodies in order to increase the speed by which certain services are executed. We categorise facilitation payments under the same umbrella as bribes unless the public body officially has defined a pricing structure which includes “express services”.
In case a facility payment has to be made in order to safeguard safety of employees and protection of our assets, this transaction will be reported to the employee’s line manager, and monitored at Group level.
4. Money laundering
Money laundering is defined as transforming money originating from illegal activities into perceived legitimately obtained funds. The ROCKWOOL Group does not allow participation in any money laundering activities. All financial transfers to and from the ROCKWOOL Group must be completely transparent, traceable and must be documented. In case we suspect any of our business partners to be involved in money laundering, we will immediately stop the cooperation.
We do not accept financial transactions to and from the following type of accounts, unless they can be legally justified:
a) Numbered accounts
b) Accounts registered in a country other than the home country of our business partner
c) Accounts registered in a name other than that of our business partner
d) Accounts registered in countries well known for non-transparent tax practices unless the country is home base of the business partner
5. Protection money
Protection money is defined as money paid to criminal elements in return for protection of the Group’s employees, assets, IT systems and/or legitimate business relationships.
In some countries it is necessary to contract with third parties to protect ourselves from criminal intimidation. We contract with legally recognised companies with good reputations. Any such contract is to be approved in Group Legal Affairs.
6. Gifts
6.1. Gifts received from business partners
ROCKWOOL employees should refrain from accepting gifts of a personal nature from business partners. A gift does not cover an invitation to dinner, lunch or event that is in the normal course of a business activity.
Exceptions to this are:
a) Special occasion gifts such as milestone birthdays, special employment anniversaries, major promotions or employment placements and retirement.
b) Supplier or customer logoed items of a value similar to our own internal guideline as described in the following section.
c) Gifts where it would be insulting to not accept the gift or to refuse could harm the relationship.
With the exception of received gifts or logo gifts of small value, gifts are considered company property and will be collected by the relevant HR department. If possible these gifts will be distributed in the organization through for example a lottery.
6.2. Gifts given to business partners
The following thresholds will apply for gifts to be given to ROCKWOOL business partners:
a) < EUR 30– common commercial items for regular business distribution.
b) EUR 30 – EUR 100 – items meant for special business relations or occasions. These items require approval by the OPCO Managing Director.
Where possible, gifts given to business partners should be marked with the ROCKWOOL or ROXUL logo or a company product mark or logo.
Special gifts exceeding a value of EUR 100 must be approved by the OPCO Managing Director and recorded in the Group intranet site monitored by Group Audit.
There should be no differentiation between government and private business partners in regards of the thresholds set.
6.3. Regular Business Activities and Events
The following thresholds apply for regular business meetings or events with customers, suppliers and other business associates:
a) Regular business activities should not exceed a cost of EUR 150 per participant.
b) Events exceeding a cost of EUR 150 per participant must be pre-approved by the OPCO Managing Director or the Vice President in charge and recorded in the Group intranet site monitored by Group Audit.
6.4. Internal representation
The following thresholds apply for activities that involve ROCKWOOL employees only:
a) Normal meetings or events should not exceed a cost of EUR 150 per participant
b) Events exceeding a cost of EUR 150 per participant must be preapproved by the OPCO Managing Director or the Vice President in charge and recorded in the Group site monitored by Group Audit
6.5. Contribution to political parties
We wish to stay completely independent from political party interests in any country. We therefore do not contribute financially to political organisations.
7. Fraudulent employee behaviour
Employees who have been caught in fraudulent behavior will be reported to the police and compensation for losses to the Group will be legally filed. All fraud cases will be published on the Group intranet.